The bill adds a new Part F to title XXVII of the Public Health Service Act that forces health care sharing ministries (as defined in the Internal Revenue Code) to disclose detailed financial, operational, and claims‑handling information to federal agencies and to current and prospective enrollees. It also conditions payment to third‑party enrollers on those enrollers providing point‑of‑sale comparisons to federal health coverage options and explains consumer rights and limitations under the sharing ministry.
Separately, the Federal Trade Commission must publish twice‑yearly summaries of consumer complaints about these ministries, including the name of the ministry and ownership/executive details. The measure is aimed at making an otherwise opaque alternative to insurance more visible to regulators, researchers, and consumers — while creating new compliance duties for ministries and anyone who enrolls members on their behalf.
At a Glance
What It Does
The bill requires health care sharing ministries to file annual reports with HHS, the IRS, and the CFPB containing specified financial, membership, claims, and provider‑contract information, and requires HHS to publish that data online. It mandates written, prominent disclosures to prospective and current enrollees about appeals rights, reimbursement uncertainty, covered/excluded items, average out‑of‑pocket costs, and reimbursement timing, and imposes conditions for third parties that enroll members.
Who It Affects
Health care sharing ministries that qualify under section 5000A(d)(2)(B)(ii) of the Internal Revenue Code, third‑party enrollment entities or brokers who receive remuneration for enrollments, federal agencies (HHS, IRS, CFPB, FTC) that will receive and publish information, and consumers considering these plans.
Why It Matters
The bill treats sharing ministries like information‑sensitive actors rather than insurers: it forces public visibility into reserves, claims payments, denials, and contractual networks. That changes the compliance baseline for ministries and creates a richer evidence base for regulators and consumer advocates evaluating consumer risk and marketplace impacts.
More articles like this one.
A weekly email with all the latest developments on this topic.
What This Bill Actually Does
The bill creates a new federal reporting and consumer‑disclosure regime targeted at organizations that identify as health care sharing ministries under the Internal Revenue Code. Each ministry must submit a standardized annual package of data to HHS, the IRS, and the CFPB — everything from reserves and membership counts to the share of money collected that was spent on items analogous to medical loss and administrative costs, denial rates, and the average time to reimburse claims.
HHS must post these filings on a public website so researchers, clinicians, and consumers can compare transparency across ministries.
Prospective and current enrollees must receive a plain‑language disclosure immediately before enrollment that explains how to appeal, whether arbitration is required, that reimbursements are not guaranteed, any lifetime sharing caps, average enrollee out‑of‑pocket costs, and a detailed list of excluded items and conditions that would render otherwise eligible items nonreimbursable. The bill prescribes presentation rules: disclosures must be prominent, offered in multiple languages, provided just before enrollment, and be at least 14‑point font (or read aloud if enrollment happens by phone).Entities that enroll people on behalf of ministries — whether brokers, call centers, or lead‑generation firms that receive remuneration — must give enrollees straightforward comparisons between ministry sharing and federally supported coverage.
Specifically, they must explain eligibility for premium tax credits (section 36B), Medicaid or Medicare eligibility, and direct contrasts in required benefits and cost‑sharing protections. The bill bars ministries from contracting with enrollment entities that fail to provide that information.For enforcement, HHS can impose civil monetary penalties of up to $100 per day per individual affected by a ministry’s failure to comply; the bill ties procedural elements of penalty enforcement to existing statutory mechanisms.
The Secretary also has authority to define unclear terms and clarify how the new rules apply to particular ministries. Separately, the FTC must publish twice‑yearly complaint tallies and categories, and include the names of ministries and leadership/ownership details when complaints are filed — making public the types and targets of consumer friction the FTC sees.
The Five Things You Need to Know
The bill requires ministries to report annually to HHS, the IRS, and the CFPB on reserves, enrollment counts, total member payments, total ministry payments for covered items, denial rates, and average claim reimbursement time.
HHS must publish the submitted ministry data on a public website, making the financial and operational metrics publicly searchable.
Prospective enrollees must receive a prominent, multilingual disclosure immediately before enrollment in at least 14‑point font (or read aloud for phone enrollments) listing exclusions, appeals processes, average out‑of‑pocket costs, and whether lifetime sharing caps exist.
An entity that receives remuneration to enroll people in a ministry may not contract with the ministry unless it explains premium tax credits (section 36B), Medicaid/Medicare eligibility, benefit and cost‑sharing differences, and that the ministry is not insurance.
The bill authorizes HHS to impose civil monetary penalties of up to $100 per day for each individual affected by a ministry’s failure to comply, and requires the FTC to publish complaint counts and ministry names twice yearly.
Section-by-Section Breakdown
Every bill we cover gets an analysis of its key sections.
Creates a new statutory home for health care sharing ministry rules
The bill inserts a new Part F into title XXVII of the Public Health Service Act and places all ministry disclosure, enrollee‑notice, entity‑requirement, enforcement, and definitional authority under a single statutory section (2799C–1). That consolidates new obligations in the federal health law framework that normally governs group and individual market standards, which matters because it puts ministries within the visibility of health‑care statutes rather than leaving them solely to tax rules or state regulation.
Core disclosure and contracting prohibitions
Subsection (a) establishes three baseline obligations: annual reporting to HHS/IRS/CFPB; required disclosures to anyone seeking to enroll or already enrolled; and a prohibition on contracting with or paying enrollment agents who do not meet the statutory entity requirements. Practically, this turns enrollment intermediaries into compliance touchpoints: ministries must ensure their partners are providing federally required comparisons and notices before receiving payment.
Detailed annual reporting fields and public posting
Subsection (b) lists the precise data ministries must submit — reserves, a specified ratio relating collected funds to expenditures (referencing analogues to section 2718(a) cost categories), enrollment totals, total member payments and ministry payouts, average enrollee OOP costs, denial percentages, provider contractual lists, and average reimbursement timelines. The subsection directs the Secretary to publish these filings on a public website, creating longitudinal, comparable data that regulators and the public can use to assess solvency, claims performance, and network reach.
Mandatory enrollee disclosures and presentation rules
Subsection (c) requires ministries to give prospective and current members a plain‑English packet that explains appeals avenues, arbitration or other legal recourse, that reimbursements are not guaranteed, lifetime sharing caps if any, and specific exclusions. It also mandates format and timing: the material must be prominent, available in multiple languages, provided immediately before enrollment, and delivered in at least 14‑point type or read aloud when enrollment occurs by phone — rules intended to prevent ‘burying’ important limitations in fine print.
Requirements for entities that enroll members
Subsection (d) conditions compensation to enrollment entities on providing customers certain comparative information: whether they qualify for premium tax credits under section 36B, whether they qualify for Medicaid or Medicare, how required benefits and protections differ between those public plans and the ministry, and explicit statements that the ministry is not group health insurance. This provision forces enrollment agents to surface federal coverage alternatives at the point of sale, shifting the informational burden from consumer research to the enrollment channel.
Enforcement: civil monetary penalties and procedural rules
Subsection (e) authorizes HHS to levy civil money penalties of up to $100 per day for each individual affected by a ministry’s failure to comply with the statute and ties penalty procedures to existing enforcement provisions elsewhere in the statute. The per‑individual, per‑day structure creates exposure that can scale quickly depending on violation breadth and duration; the cross‑reference to established penalty process language governs hearings, appeals, and collections.
Secretary’s definitional authority and FTC complaint reporting
Subsection (f) gives the Secretary authority to define undefined terms and clarify applicability, which effectively delegates substantive interpretive judgment to HHS during implementation. Separately, the bill amends FTC disclosure practice: beginning at the next Jan. 1 or July 1 after a 90‑day startup, the FTC must publish twice‑yearly complaint counts and categories, and identify the ministry named in each complaint along with ownership/leadership information — a requirement that will make complaint patterns and the names of frequently complained‑about ministries publicly visible.
This bill is one of many.
Codify tracks hundreds of bills on Healthcare across all five countries.
Explore Healthcare in Codify Search →Who Benefits and Who Bears the Cost
Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Prospective and current enrollees — receive mandatory, plain‑language disclosures at point of sale explaining appeals, exclusions, average out‑of‑pocket costs, and reimbursement uncertainty, improving their ability to compare options.
- Regulators and consumer advocates — gain standardized, public data (reserves, payouts, denial rates, provider relationships) to monitor solvency, market conduct, and consumer harm trends.
- Researchers and journalists — obtain a new public dataset on non‑insurance health coverage performance and complaints that can support empirical work on access and financial risk.
Who Bears the Cost
- Health care sharing ministries — must build data‑collection, recordkeeping, and reporting systems and update member communications and enrollment processes; small ministries may face disproportionate compliance costs.
- Third‑party enrollment entities and brokers — must integrate mandatory tax‑credit, Medicare/Medicaid eligibility, and benefit‑comparison disclosures into sales scripts and materially change compensation relationships to comply.
- Federal agencies (HHS, IRS, CFPB, FTC) — face new intake, publication, and oversight workloads to receive filings, publish data, and maintain FTC complaint reporting, likely requiring staff time and systems changes.
Key Issues
The Core Tension
The central dilemma is between transparency for consumer protection and the potential regulatory overreach into faith‑based, non‑insurance arrangements: requiring insurer‑like reporting and point‑of‑sale comparisons protects consumers and creates public data, but it imposes accounting, legal, and operational burdens that could shrink or reshape the market for sharing ministries — a trade‑off with no easy resolution between disclosure‑driven protection and preserving a distinct, voluntary model of health sharing.
The bill forces a commercial‑style transparency regime onto entities that have historically operated outside insurance regulation, but it leaves several practical implementation questions unresolved. The reporting fields borrow insurance‑market concepts (for example, a ratio tied to section 2718(a) cost categories) without specifying how ministries — which do not operate as insurers — should map their accounting to those categories.
That ambiguity will create high administrative friction during the first reporting cycles and give the Secretary substantial interpretive authority.
Naming ministries in FTC complaint reports increases public accountability but raises accuracy and legal‑risk concerns: complaints vary widely in merit, and public naming without adjudication could generate reputational harms that complicate enforcement and invite litigation. The civil penalty structure — $100 per day per affected individual — can create large financial exposure for technical or transient violations, and the bill does not calibrate penalties to ministry size or revenue, which may push small ministries out of operation or trigger aggressive legal defense strategies that bog down enforcement.
Finally, the requirement that enrollment entities present federal coverage alternatives could improve consumer awareness but also risk becoming a compliance checkbox that busy enrollers recite mechanically, especially if federal agencies do not provide standardized scripts or training.
Try it yourself.
Ask a question in plain English, or pick a topic below. Results in seconds.